August 29, 2019

J. Mark Goode
Chief Executive Officer
Hash Labs Inc.
78 SW 7th Street
Miami, FL 33130

       Re: Hash Labs Inc.
           Amendment No. 2 to Registration Statement on Form S-1
           Filed July 30, 2019
           File No. 333-228042

Dear Mr. Goode:

     We have reviewed your amended registration statement and have the
following
comment. Our reference to a prior comment is to the comment in our April 26,
2019 letter.

       Please respond to this letter by providing the requested information. If
you do not believe
our comment applies to your facts and circumstances or do not believe an
amendment is
appropriate, please tell us why in your response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this comment, we may have additional comments.

Amendment No. 2 to Registration Statement on Form S-1

General

1.     We have reviewed your revised disclosure, including your removal of
references to the
       issuance of a digital token, and your response to prior comment 1. We
continue to believe
       that the gold program offered through the Coro mobile application will
involve the offer
       and sale of securities under the Securities Act of 1933. In this regard,
we note that the
       gold program, as revised, appears to involve the offer and sale of an
investment contract
       under which users will be able to purchase interests in unallocated pool
of gold. The facts
       we noted in prior comment 1 do not appear to have materially changed,
other than the fact
       you have removed references to the digital token. However, this does not
appear to
       change the investment contract analysis as the interests in the gold
program continue to be
       essentially fungible and transferable. Moreover, the fact that you
intend to operate a
       money transmission business does not change the investment contract
analysis because
       money transmission businesses can offer and sell securities.
Accordingly, please tell us
 J. Mark Goode
Hash Labs Inc.
August 29, 2019
Page 2
      how you intend to register the offering of the interests in the gold
program, or the
      exemption from the registration requirements of the Securities Act of
1933 you will rely
      on to conduct the offering.

      If you disagree with our conclusion, please provide us with a detailed
legal analysis
      explaining your position. Your analysis should include a detailed
description of the
      operation of the gold program, including the specific rights users have
with respect to the
      pool of gold. Your analysis also should compare and, if applicable,
distinguish the
      offering of interests in the gold program from other offerings of
interests in gold programs
      registered under the Securities Act of 1933, such as the Vaulted Gold
Bullion Trust with
      its issuance of Gold Deposit Receipts. Your analysis should continue to
address Gary
      Plastic Packaging Corp. v. Merrill Lynch, Pierce Fenner & Smith, 756 F.2d
230 (2d Cir.
      1985).
      Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or, in
his absence, Jan
Woo, Legal Branch Chief, at (202) 551-3453 with any questions.



                                                            Sincerely,

FirstName LastNameJ. Mark Goode                             Division of
Corporation Finance
                                                            Office of
Information Technologies
Comapany NameHash Labs Inc.
                                                            and Services
August 29, 2019 Page 2
cc:       Thomas A. Rose, Esq.
FirstName LastName